1. Purpose

This policy outlines asia bigwave’s commitment to ethical business practices, ensuring compliance with malaysian anti-bribery and anti-money laundering laws. It serves to prevent corruption, bribery, and money laundering within the company’s operations and to protect its reputation and stakeholders.

2. Scope

This policy applies to:

1.All employees, contractors, and third-party vendors working with or on behalf of asia bigwave.
2.All activities, including client interactions, vendor negotiations, and internal operations, within malaysia and internationally.

3. Definitions

• Bribery:
  Offering, giving, receiving, or soliciting something of value as a means of influencing the actions of an individual or organization.
• Money laundering:
  Concealing or disguising the origins of illegally obtained money to make it appear legitimate.

4. Policy

• Zero tolerance for bribery:
  ○employees and contractors are prohibited from offering, accepting, or soliciting bribes, kickbacks, or gifts beyond nominal value in any form.
• All gifts or entertainment provided to clients or received from vendors must be disclosed to management for approval.
• Prohibition of facilitation payments:
  ○the company strictly prohibits facilitation payments (unofficial payments to expedite or secure routine actions).
• Third-party relationships:
  ○all third-party vendors and contractors must comply with this policy. Due diligence will be conducted before engagement to ensure alignment with the company’s ethical standards.
• Conflict of interest:
  ○employees must disclose any personal relationships or financial interests that could create conflicts of interest.
• Anti-money laundering measures:
  ○the company will ensure thorough client and vendor verification (e.G., know your customer (kyc) procedures).

○suspicious transactions or activities must be reported immediately to the designated compliance officer.

5. Reporting and whistleblowing

• Reporting mechanism:
  ○employees and stakeholders are encouraged to report any suspected bribery, corruption, or money laundering activities.
  ○reports can be made confidentially to eskay@asiabigwave.Com.
• Whistleblower protection:
  ○individuals reporting violations in good faith will be protected from retaliation or adverse consequences.

6. Training and awareness

• Employee training:
  ○all employees will receive training on anti-bribery and anti-money laundering practices upon joining and periodically thereafter.
• Policy awareness:
  ○copies of this policy will be made available to all employees and third-party vendors.

7. Enforcement and penalties

• Disciplinary action:
  ○violations of this policy will result in disciplinary actions, including termination of employment or contracts, and may result in legal consequences.
• Legal compliance:
  ○non-compliance with malaysian laws (e.G., malaysian anti-corruption commission act 2009) may lead to legal proceedings and penalties.

8. Review and updates

This policy will be reviewed annually or as required to ensure compliance with changes in laws or company operations.